New requirements for Subject Persons when assessing risk

In October 2020, the FATF revised Recommendation 1 and its Interpretive Note (R.1 and INR.1) to require countries and Subject Persons to identify, assess, understand and mitigate their proliferation financing risks. Proliferation financing risk refers strictly and only to the potential breach, non-implementation or evasion of the targeted financial sanctions (TFS) obligations referred to in Recommendation 7.3.

In addition to obligations for countries, the revised FATF Standards require Subject Persons to have in place processes to identify, assess, monitor, manage and mitigate proliferation financing risks. Subject Persons may do so within the framework of their existing sanctions and/or compliance programmes and are not expected to establish duplicative processes for proliferation financing risk assessment or mitigation.